Privacy Policy
[Last Updated: June 19, 2024]
The Promise Act program provides grant funding to support disadvantaged small businesses in certain neighborhoods in Minnesota. The Promise Act program is overseen by the Minnesota Department of Employment and Economic Development and, in the Twin Cities, is administered by the Neighborhood Development Center (“NDC,” “we,” and “us”). You can find more information on the Promise Act program here.
This Privacy Policy (“Policy”) applies to the personal information collected by the NDC from applicants and prospective applicants in connection with the Promise Act grant program. To that end, it describes the personal information we collect, how we use that information, who we disclose it to, and certain rights and options that may be available in connection with such personal information. This Policy applies to information we collect through the grant application portal, as well as through your pre-application questionnaire, application, identity verification process, and when you communicate or otherwise provide us with information.
Important Information About This Policy
During the grant application process, if any of the information provided about you or your organization is no longer accurate, please notify us promptly so we can amend our records accordingly. By using the application portal, communicating with us, or otherwise interacting with us, you consent and agree to our collection, use, sharing and disclosure of your information as described in this Policy. You are not required to provide the information requested through the application process, but failure to do so may result in the denial of your application for this grant program.
Note: upon completion of the evaluation process, data you have provided will be public (except for trade secret data as defined and classified in Minn. Stat. § 13.37). For more information about data classification relating to grants, please refer to Minn. Stat. § 13.599.
Information We Collect or Receive About You
Personal Information
For the purposes of this Policy, “personal information” is any information that, either alone or in combination with other information, identifies, relates to, or can be used to contact a particular individual. The types of personal information we may collect include the following categories.
Contact information: First and last name of individual submitting the application, first and last name of principals of your organization, name of your organization, business email address, postal address, telephone number, and other contact information you supply to us.
Application portal data: Username and password for the account associated with your organization’s account, as well as information relating to your usage of the application portal, including dates/times you log into the portal, the IP address used to log into the portal, and information relating to the device used to connect to the portal (such as device ID, type of device, and similar information).
Terms of Service for the PROMISE Act Grant Application Portal can be found here.
Pre-application and application information: Contact information (as described above), information about the entity applying for the grant (including certain revenue and tax information, such as federal employer identification number, secretary of state registration file number, Minnesota tax ID number, etc.), names of individuals that own 20% or more of the organization, and demographic information of the organization’s owners (including race, gender, ethnicity, disability status, and similar information) as may be required pursuant to the Promise Act program’s guidelines.
Identity verification information – Background information concerning applicants that may be requested by our third-party partner to verify the identity of applicants.
Support information: Copies of communications and inquiries you have submitted to us, including through email, calls, and features available in application portal.
Device and usage information: Details regarding how and when you use our application portal, including the device used to connect to the portal, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what website or search terms referred you to the portal, and information about your interaction with the portal.
We collect this information when you access, use, or navigate our application portal, fill in forms on or upload information to the application portal, request information from us, communicate with us (including by phone, email, or otherwise), or otherwise provide us with personal information.
Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.” We may also collect information about you from third-party sources and information about you that is publicly available.
Automatically Collected Usage and Device Information
Like most websites, we use various technologies to collect certain types of information about the users of our application portal. These technologies include:
Cookies: Cookies are small text files that can be used by websites to make a user’s experience more efficient. Our application portal uses cookies to, among other things, automatically recognize you when you return to our site, store information regarding your preferences, and analyze traffic to our portal. Please note that where cookies are essential to the operation of our site, if disabled, you may not be able to enjoy certain features of the site. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. We do not honor “Do Not Track” signals.
Log Files and Device Identifiers. We use log files to track actions occurring on the portal and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
Pixels, tags, web beacons and other technologies. Our portal may also use “pixels,” “tags,” “web beacons,” or other similar technologies. These technologies are small pieces of code that run when a website page or email is loaded. They are used to monitor the behavior of the visitor or email recipient—such as what icons were clicked or whether links in an email were opened—and gather analytics. For example, when you open our portal, a pixel may run and generate information based on the visit, and then this information is processed by us or our vendors. Pixels work in conjunction with cookies to let us know what portions of our portal are of interest to you. If you turn off cookies, the pixels, tags, and web beacons we use may still detect certain information about your interaction with our portal and disregard any cookie-prohibitive markers or signals. Note, the vendors that supply us these pixels, tags, web beacons, cookies, or similar tracking technologies collect your personal information instantaneously and simultaneous to our collection of such information and they may use the information for their own purposes.
Analytics. Our portal may also use third-party analytics tools, such as Google Analytics. You can find more information about how data is collected and processed in connection with the Google Analytics service here. You can also read Google’s privacy policy here.
The information collected through these technologies may be combined with personal information or aggregated with other information on portal visits. We may share information about your use of our portal with our analytics partners, who may combine it with other information that you previously provided to them.
How We Use Your Information
We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:
Reviewing your application for, evaluating your eligibility for, and administering the Promise Act grant program.
Providing the application portal and optimizing your experience with the portal.
Communicating with you and responding to your inquiries and communicating regarding the Promise Act grant program, your organization’s application, and other issues, and otherwise managing issues with the grant application process and portal.
Reporting information and statistics regarding grant applicants to the Minnesota Department of Employment and Economic Development, per our contractual and legal requirements.
Conducting surveys to learn more about your experience with the grant application process and portal, or otherwise soliciting feedback from you.
Developing, updating, and improving the application portal, and otherwise improving our knowledge and insights regarding applicants.
Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the grant application process and portal.
Complying with our legal or regulatory obligations and defending or advancing legal claims.
Notifying you about changes to the application program and portal or material changes to this Policy.
Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.
For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Personal Information” below.
Disclosure of Your Information
We may disclose your personal information to the following types of third parties:
The Minnesota Department of Employment and Economic Development and other governmental entities necessary for the oversight and administration of the Promise Act program.
Service providers we use to facilitate our administration of the grant application process and portal. For example, our service providers include (i) IT and system administration providers, (ii) entities that host our application portal, (iii) data storage providers, and (iv) the vendor that facilitates ID verification in connection with grant applications.
Analytics vendors to understand our traffic and usage patterns in connection with the application portal.
Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
Our professional advisors, such as lawyers, accountants, and other similar advisors.
Other parties for any purpose we disclose at the time you provide the information.
When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or disclose it to third parties, to the extent permitted by applicable law.
Your Choices About Personal Information
Tracking Technologies
Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of our application portal.
Communications Relating to Your Application
You may request that we not communicate with you regarding your application. Doing so, however, may result in the denial of your application.
Google Analytics
As discussed above, we use Google Analytics in connection with the application portal. If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use. You can find more information on how Google uses information it collects here.
Updating Your Information
As indicated above, NDC relies on you to keep your organization’s application and information updated, accurate, and complete. You can access or update your organization’s information, including contact or account information by contacting us at the “Contact Us” information below or updating it yourself in the application portal.
Declining to Provide Information
You can choose not to provide us with information we may request, but that may result in us being unable to process your organization’s application.
Do Not Track Mechanisms
Please note that our application portal does not honor “Do Not Track” signals, and such signals will not impact the operation of our portal.
Information Security
We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us, and you do so at your own risk.
Privacy of Children Online
Our application portal is a general audience site and is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the portal. Please contact us via the “Contact Us” section of this Policy if you believe we may have collected information from or about a child under 13.
Links to Third-Party Websites
Our application portal may contain links to third-party websites or platforms. Such websites have separate privacy policies that you should review. We cannot take responsibility for the content of linked websites or those entities’ data-handling practices.
Changes to the Privacy Policy
Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of the application portal after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.
Contact Us
If you have any questions regarding our information handling practices, you may contact us at:
Neighborhood Development Center
625 University Avenue
Saint Paul, Minnesota 55104
Phone: 651.291.2480
Email: promiseact@ndc-mn.org